UPDATED April 1, 2020
As of April 1, 2020, many states have released guidance to extend their tax filing or payment deadlines to align with IRS Notice 2020-18 or to provide their own extended filing or payment dates, while others are still slow to take action. Additionally, on March 24, 2020, the IRS has also released information addressing Frequently Asked Questions (FAQs) and on March 27, 2020 the IRS issued Notice 2020-20. Today’s blog will update you on the most current information available regarding federal, state and select local tax filing and payment deadlines.
Note: In future blog posts, we will begin dissecting the next Coronavirus relief bill that becomes law. Whatever bill passes, it will lack many details. Instead it will be up to the Treasury to fill in many of the procedural details, which will take longer than any politician will admit. The AICPA is working closely with the Treasury and IRS to expedite guidance where possible. The Tax Warriors thank them for their leadership during these unprecedented times.
We are regularly updating our COVID-19 Tax Resource Center tax and business related issues affected by the Coronavirus pandemic. Please bookmark and check this page for the latest updates.
IRS Filing and Payment Deadline FAQs
The IRS Released Filing and Payment Deadlines Questions and Answers in response to Notice 2020-18 on March 24, 2020 and released Notice 2020-20 to update Notice 2020-18. The key points clarified in the current FAQ posted and Notice 2020-20 include:
- Income Tax Forms that the notice postpones filing and payment dates include:
- Form 1040, 1040-SR, 1040-NR, 1040-NR-EZ, 1040-PR, 1040-SS
- Form 1041, 1041-N, 1041-QFT
- Form 1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-SF
- Form 8960
- Form 709
- Form 8991 (Base Erosion and Anti-Abuse Tax payments)
- Section 965 installment payments due on April 15, 2020
With respect to Form 990-T, if that Form is due to be filed on April 15, then it has been postponed to July 15 under the Notice. For taxpayers whose Form 990-T is due on May 15, that due date has not been postponed under the Notice.
- If your Federal income tax return for your fiscal year ended during 2019 is due on April 15, 2020, whether that is the original due date or the due date on extension, your due date is postponed to July 15, 2020.
- Any taxpayers who have filing or payment due dates other than April 15 have not been granted relief at this time.
- If you do not anticipate filing a return due on April 15, 2020 by July 15, 2020, you will need to file Form 4868 or 7004 by July 15, 2020. All anticipated tax payments should be made by July 15, 2020 to avoid interest and penalties after that date.
- Second quarter 2020 estimated income tax payments are still due on June 15, 2020.
- 2019 IRA, HSA and Archer MSA contributions must be funded by the July 15, 2020 extended due date.
- Any 2016 refund claims due on April 15, 2020 are NOT extended.
The AICPA has compiled a list of additional questions which are not answered by the recent guidance provided by the IRS and is working closely with the Treasury to get answers as soon as possible.
Bloomberg Tax & Accounting has compiled a State Tax Coronavirus Road Map that is being updated continuously. Similarly the AICPA created a State Filing Guidance for Coronavirus Pandemic Chart which is being updated regularly and includes federal tax resources.
Below is a summary of the guidance available in the states and localities a lot of our clients file in:
California – On March 18, 2020 the Franchise Tax Board updated its previous guidance further extending relief being offered to CA taxpayers. The FTB is postponing, until July 15, the filing and payment deadlines for all individuals and business entities for:
- 2019 tax returns
- 2019 tax return payments
- 2020 1st and 2nd quarter estimated payments
- 2020 LLC taxes and fees
- 2020 Non-wage withholding payments
Connecticut – On March 20, 2020, at the direction of Governor Lamont, the Connecticut Department of Revenue Services extended the filing and payment deadline for personal income tax returns 90 days, to July 15, 2020. The extension also applies to Connecticut estimated income tax payments for the first and second quarters of 2020.
Delaware – On March 23, 2020 the Delaware Division of Revenue issued Technical Information Memorandum 2020-1. The relief outlined in this TIM will be automatically provided to all affected taxpayers as follows:
- Corporate tentative returns that would be due on April 15, 2020 pursuant to 30 Del. C. § 1904(a) will now be due on July 15, 2020.
- Personal income tax returns that would be due on April 30, 2020 will now be due on July 15, 2020. If a taxpayer needs additional time beyond the extended due date, taxpayers may request an extension requesting additional time to file through the Division of Revenue’s online system. This will provide an automatic extension of time to file to October 15, 2020. This requires the submission of Form 1027, available on the Division of Revenue website
- Estimated personal income tax payments that are due on April 30, 2020 are extended to July 15, 2020. Please note that the second quarter payments remain due on June 15, 2020.
- Fiduciary income tax returns that are due on April 30, 2020 will now be due on July 15, 2020. If a taxpayer needs additional time beyond the extended due date, the Division of Revenue reminds all taxpayers that they may file an extension requesting additional time to file. This will provide an automatic extension of time to file to October 15, 2020. This requires the submission of Form 400-EX, available on the Division of Revenue website.
Massachusetts – On March 27, 2020, Governor Baker announced “Massachusetts will move the state personal income tax filing and payment deadline to July 15, consistent with the federal government, in order to provide additional flexibility to filers during this crisis..."
New Jersey – As of March 31, 2020 a Joint Statement by Governor Murphy, Senate President Sweeney, and Assembly Speaker Coughlin read: "The ongoing COVID-19 pandemic has caused hardships....for many...As part of our response, we have reached agreement that the state income tax filing deadline and the corporation business tax filing deadline will be extended from April 15th to July 15th...."
New York & New York City - As of March 29, 2020, New York released N-20-2 announcing the Commissioner has extended the April 15, 2020 due date to July 15, 2020, for New York State personal income tax and corporation tax returns originally due on April 15, 2020. Except as specified in N-20-2, this extension applies to returns for individuals, fiduciaries (estate and trusts), and corporations taxable under Tax Law Articles 9, 9-A and 33. In addition, the Commissioner is allowing taxpayers to defer all related tax payments due on April 15, 2020, to July 15, 2020, without penalties and interest, regardless of the amount owed.
Pennsylvania - Late on March 25, 2020 the PA Legislature amended House Bill 1232. This Bill, among other things, temporarily authorizes the Department of Revenue to extend filing and payment deadlines to coincide with the extended federal deadline of July 15, 2020, as follows:
- Extends the deadline for declarations of estimated personal Income Tax (PIT)
- Extends the deadline for payments of estimated PIT; and
- Extends the deadline for the filing of informational returns related to the PA s-corporations, partnerships, estates and trusts.
The Pennsylvania Department of Revenue announced it has extended 2019 individual income tax filing and payment deadlines to July 15, 2020. Additionally, the first and second quarter 2020 individual estimated tax deadlines were also extended to July 15, 2020.
On March 23, 2020, The Philadelphia Department of Revenue announced it extended the 2019 tax year filing and payment deadlines to July 15, 2020 for the Business Income and Receipts Tax (BIRT) and Net Profits Tax (NPT).
On March 31, 2020, Philadelphia announced businesses ordered to close beginning March 17, 2020 as a result of safety measures enacted by the Mayor of Philadelphia are not subject to the Use & Occupancy (U&O) Tax while access to their place of business is restricted. Once the order to close non-essential businesses is lifted, all property used for business purposes is subject to Use & Occupancy Tax. Businesses that continued operations, businesses that have employees on-site, and businesses that maintained employee access to their place of business throughout the Mayor’s order, should file and pay the Use & Occupancy Tax as normal. The Philadelphia Department of Revenue has not changed Use & Occupancy payment regulations. Due dates to file and pay the tax remain the same. When filing, taxpayers should use “Line 3 - Non-taxable Exempt Amount” of the filing form to indicate the portion of their property that was not accessible through the closure order.
Regardless of extensions granted, the City encourages all taxpayers who can file and pay on time to do so in order to ensure the continuity of critical city and School District services.
Philadelphia non-resident employees based in Philadelphia are not subject to Philadelphia Wage Tax during the time they have been ordered to work outside of Philadelphia. Read more here.
Various PA Localities – Late on March 25, 2020 the PA Legislature amended House Bill 1232. The legislation authorized the Department of Community and Economic Development (DCED) to coordinate with the governing bodies and local agencies of political subdivisions to extend filing and payment deadlines for the local Earned Income Tax (EIT). Both Berkheimer and Keystone Collections Group, the two major tax administrators and collectors for local jurisdictions in PA with earned income tax, note on their web sites that 2019 local earned income tax returns and first quarter estimated tax payments for individual normally due April 15, 2020 are now due July 15, 2020, in alignment with the relief granted by Pennsylvania.
Continue to visit our COVID-19 Tax Resource Center for up-to-date information on how the outbreak may impact your tax filing, payments, and planning. We encourage you to share the page with other business owners. Through this unprecedented series of events, you can count on The Tax Warriors® at Drucker & Scaccetti to help. Call on us for assistance.
Topics: New York, New Jersey, Philadelphia, Pennsylvania, Delaware, Pass-Through Business Alternative Income Tax Act, state and local taxes, Deadline extension, Relief Package, COVID-19, Deferred tax payments, July 15th, Coronavirus Response Act